Constitutional Law Keyed to Stone

Brief Fact Summary. Nancy Cruzan was involved in a car accident, which left her in a “persistent vegetative state.” After it became clear that Cruzan would not improve, her parents requested that the hospital terminate the life-support procedures the hospital was providing. The hospital and subsequently the State court refused to comply.

Synopsis of Rule of Law. A State may condition the exercise of a patient’s right to terminate life-sustaining treatment on a showing of clear and convincing evidence of the desire of the patient to exercise such a right.

Facts. Nancy Cruzan was involved in a car accident, which left her in a “persistent vegetative state.” In order to feed her and to facilitate her recovery, surgeons implanted into her a gastronomy feeding and hydration tube. After it become apparent that Cruzan had virtually no chance for recovery, Petitioners, Cruzan’s parents, asked hospital employees to terminate the life support procedures. The State hospital employees refused to honor this request without court approval. After trial, on appeal, the Missouri Supreme Court refused to order termination of the life-support, because clear and convincing evidence was not produced to show that Cruzan herself would have chosen to refuse treatment.

Issue. Did Cruzan have a right under the United States Constitution that would require the hospital to withdraw life-sustaining treatment? Did Missouri’s procedural requirement for clear and convincing evidence of an incompetent person’s desire to terminate life support before it is terminated violate the Constitution?

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